People v. Bloxson

In People v. Bloxson, 205 Mich App 236; 517 NW2d 563 (1994), the Court held that a seizure occurred where officers approached and questioned the defendant on a bus. In concluding that the encounter involved a restraint on the defendant's liberty sufficient to become a seizure, the Court considered the defendant's confinement on the bus and "the fact that the detective was standing over the defendant and between the defendant and the bus door." Id. at 244-245. The Court noted that the officers' conduct under these circumstances communicated to the defendant that he was not free to decline the officers' requests. Id. at 244.